Strategy Desk Privacy Policy

Preamble

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, and disclosure of “personal information” by Strategydesk.com (“SD” or “Strategy Desk”), a privately owned website which is not owned wholly or in part by any registered company. This Privacy Policy includes products and services provided through websites that Strategy Desk operates, which include, but are not limited to, http://www.strategydesk.com (the “SD Website”) and any other related or separate website forming part of the Strategy Desk group, (collectively, the “Websites”). Furthermore, this Privacy Policy does not apply to any of the websites operated by affiliates of Strategy Desk or third parties.

In addition, additional or supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to a particular Website or service provided thereon. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that Website or service.

This Privacy Policy also explains our commitment to you with respect to our use and disclosure of non personal browsing and site usage data that Strategy Desk collects as the provider of the Websites. That commitment is contained in a “Data Usage Policy” below.

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address.

By accessing the Websites or using any of the Strategy Desk services, you are accepting and agreeing to the practices described in this Privacy Policy.

Our Principles

Strategy Desk is committed to handling responsibly the information and data we collect about you through our Websites, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy and our Data Usage Policy consistent with the following principles (the “Principles”):

  1. Privacy policies and data collection and use policies should be human readable, comprehensive, and easy to locate. Only the permitted amount of information required to provide you with services, enable LasyTrips to comply with any legal or applicable regulations or facilitate Strategy Desk to anonymously use data for commercial purposes should be collected and maintained, and only for so long as reasonably needed or required;
  2. Information you provide through our Websites, or that we gather as a result of your use of our Websites or related services, should not be used for marketing or advertising purposes unless explicitly permitted, nor should it be provided voluntarily (without your permission) to anyone else unless required; and
  3. If Strategy Desk is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, Strategy Desk will use reasonable means to notify you promptly of that event, unless prohibited by law or SD is otherwise advised not to notify you on the advice of legal counsel.

Personal Information SD Collects

We may collect personal information at several places on the Websites, including without limitation:

  1. in connection with your viewing of any part of the SD Websites including any data directly or indirectly provided to us as part of said viewing;
  2. when you provide us with your personal information such as by sending an email to us or signing up to receive updates, newsletters or other information from Strategy Desk;
  3. when you subscribe to one of our forum discussion lists or register to establish a user account on any of our Websites, or purchase merchandise;
  4. when you join the Strategy Desk network through our SD Website, and when you thereafter create/edit your profile page, identify your content, create directly or indirectly any content through use of the Websites, share any of your data, and/or establish an account; and
  5. when you provide personal information in connection with your participation in any of the forums we make available or any SD or third party discussion forums.

What SD does with Personal Information

Emails and Newsletters.

We use the personal information you provide to us when you send us emails or sign up to receive updates from Strategy Desk in order to respond to your request – for example, to reply to your email or to send you communications about Strategy Desk news and campaigns.

When you subscribe to updates from us, your email address is sent to and stored in a Strategy Desk SQL database hosted on Strategy Desk' or Strategy Desk' hosting service provider's servers that can only be accessed by Strategy Desk staff and contractors. Your username, name and email address could be visible to other discussion participants when you correspond on any of our forums and to the general public in the discussion archives. Options for disclosing name and email will be provided in any instance where these may be publicly accessible except in instances where these have to be legally disclosed. All emails sent to the discussions lists are archived by SD and may be archived by any third party accessing our Websites.

Purchases.

When you pay money to us through purchasing merchandise or services via any of our Websites, we will handle your personal information in accordance with this Privacy Policy.

  1. If you purchase merchandise from the Strategy Desk website, your personal information will be used for the purpose of sending you the items you purchased. If you sign up to receive updates from Strategy Desk when you check out from the store, we will use your personal information to send you communications about Strategy Desk news and campaigns.
  2. You may make payments to Strategy Desk directly or through a variety of on-line payment sites, including PayPal or our selection of card payment processing providers, among others. When you use any of those websites and services to pay money to SD, your personal information is sent to, handled by and stored by those websites in accordance with their respective privacy policies and terms of use. You should read and understand the privacy policy and terms of use of any website you use to pay Strategy Desk. When you pay money to Strategy Desk directly, we use your personal information to process your payment.

SD Website

When you join our network you provide personal information to create your account and establish a password and profile. We use that personal information to establish and maintain your accounts, provide you with the features we provide for account holders, and for the purpose of contacting you about upcoming news and events relevant to Strategy Desk.

By joining the Strategy Desk network, you are also given a public profile page where you can voluntarily post personal information for public viewing. The information that you submit on your public profile page, including but not limited to information you provide in the your private section of your profile and any photograph or image of yourself you upload, is posted by you at your discretion (although subject to SD's Master Terms of Use). The information you publish on your public profile page, including your personal information, may be used by anyone who views that information for any lawful purpose and any photograph or image of yourself that you upload, which if you choose to provide in either case must be licensed under and becomes subject to the terms and conditions of the Strategy Desk Copyright License v1.0, as stated on the applicable Terms and Conditions. SD may use the personal and non personal browsing information you provide in your public profile to promote the mission of Strategy Desk and the SD Website or commercial purposes. Anonymised grouped personal and non-personal data from the private and public sections of your profile and account can be used by Strategy Desk for commercial purposes subject to any applicable law, this Privacy Policy and the Master Terms.

Participating in Our Community: Registered Users

When you register to obtain a user account on any of the Websites (any such person, a “Registered User”), including but not limited to the Strategy Desk account (located at http://www.strategydesk.com/login) you may be asked to provide personal information to create your account and establish a password and profile. Though the first and last name fields are required, providing your legal name is optional. Provision of your email address enables us to effectively manage your account and provide enhanced security which we would otherwise not be able to do. We encourage you to use an alias or nickname if you are not comfortable providing your legal name. If you voluntarily provide your legal name in connection with any content you submit to any Website, your name may be associated with the content you contributed (such as a publicly accessible provision of your name through sharing it by way of providing data to the Websites). We will also use that personal information to establish and maintain your membership and provide you with the features we provide for Registered Users.

Any other personal information that we may collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.

Disclosures of Personal Information

In general, it is not Creative Commons' practice to disclose personal information to third parties. We may share personal information in three instances:

First, Strategy Desk may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Websites.

Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms of Use and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public.

Third, we will provide your personal information as required to any service or product which you purchase through our Websites where this service or product is provided by third parties and your personal information is necessary for the purchase of such a product or service. This may include but is not limited to products and services such as hotel bookings, flight bookings, other transport or travel purchases requiring your personal details. By accepting this Privacy Policy you allow us to share such information with the third party you purchase the above services or products if and only if you choose to perform such a transaction through the use of our Websites.

If Strategy Desk is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, Strategy Desk will use reasonable means to notify you promptly of that event, unless prohibited by law or SD is otherwise advised not to notify you on the advice of legal counsel.

Security of Personal Information Collected via the Websites

Strategy Desk has implemented reasonable measures to protect against unauthorized access to and unlawful interception or processing of personal information that Strategy Desk stores and controls. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. We will post a reasonably prominent notice to the Websites if any such security breach occurs.

Data Usage Policy: Non Personal Browsing and Site Usage Information

Our Data Usage Policy covers how we maintain and use information about you that is collected by our Websites and server logs, including when you log into a website using your Strategy Desk account.

Non Personal Browsing Information We Collect

When you use the Websites, our servers (which may be hosted by a third party service provider) may collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and information about the browser you are using. In addition, whenever you use your Strategy Desk account to log into a website, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them.

Data Linking

We may link browsing information or information from our account server logs to the personal information you submit to us. We use this information to generate non-personal aggregated data for internal and external purposes, such as to help understand how the Websites are being used, to improve our Websites and the features we provide, and for systems administration purposes as well as using aggregated anonymised non-personal data based on the personal data you provide for services we may offer to third parties. SD may use a third party analytics provider to help us collect and analyze non personal browsing information through operation of our Websites for those same purposes.

No Selling or Sharing.

Except in the unique situations identified in this Privacy Policy, Creative Commons does not sell or otherwise voluntarily provide the non personal browsing information we collect about you or your website usage to third parties. Any data we do provide will be anonymised and grouped prior to any such usage which will mean that any personal or impersonal information we hold on you will not be directly provided to third parties and any third party in possession of data we provide will never be able to directly link such information to your account or your personal information.

No Access.

As an SD account service provider, SD could technically access your web-based account tied to our SD account service, and could log in on behalf of any of its SD account users to any of the accounts they have accessed using their Strategy Desk account. Strategy Desk will never use this technical login ability for any purpose unless otherwise required by law.

Notice.

If Strategy Desk is required to provide a third party with your non personal browsing information or to log in on behalf of an Strategy Desk user (whether by subpoena or otherwise), then SD will use reasonable means to notify you promptly of that event, unless SD is prohibited by law from doing so or is otherwise advised not to notify you on the advice of legal counsel.

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.

Reorganization or Spin-Offs

Strategy Desk may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, rebranding, sale of the Websites or similar transaction. Upon such transfer, the acquirer's privacy policy will apply. In such event, Strategy Desk will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer's privacy policy complies with the Principles.

Children

The Websites are not directed at children under the age of 18. Consistent with any applicable national, federal or state legislation in every jurisdiction, we will never knowingly request personal information from anyone under the age of 18 without requiring parental consent. We permit the use of our Websites and any related services to those under 18 and we do not collect any data related to our users's age. Our Master Terms of Use specifically prohibit anyone using our Websites from submitting any personally identifiable information about persons under 18 years of age. Any person who provides their personal information to SD through the Websites represents that they are 18 years of age or older.

Third-Party Sites

The Websites may include links to other websites and information from other websites. You should consult the respective privacy policies of these third-party sites. Any information provided from a third-party website will be clearly marked by classifying it as an Advertisement or through the use of the other website's name and/or branding. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

Special Note to International Users

The Websites are hosted in the United Kingdom and may be hosted in any other legally permissible territory and jurisdiction. Please note that your personal data may be located on servers in the United Kingdom or any other territory as part of a technical outsourcing agreement. Our services are created and administered in the United Kingdom and are governed by United Kingdom law and any other applicable law and legislation. By providing your personal data you consent to the use of your personal data for the uses identified above in accordance with the Privacy Policy.

Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will also revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Websites constitutes your agreement to this Privacy Policy and any updates.

End of the Policy